Sent: Wednesday, April 11, 2001 12:19 PM
Subject: File No. S7-07-01
Jonathan G. Katz
Secretary, Securities and Exchange Commision
450 5th Street, N.W.
Washington, D.C. 20549-0609
Dear Mr. Katz,
We are pleased to see the SEC's proposed rule amendments to recordkeeping
requirements for registered public utility holding companies. However, we
feel there is an undue burden for companies to follow 257.1 (e) (2) (iii) -
"Separately store, for the time required for preservation of the original
record, a duplicate copy of the record stored on the micrographic or
electronic media or any media allowed by this section."
We feel that companies should be allowed to decide what needs to be kept in
duplicate and how long those duplicates need to be retained.
Rationale:
Once a record has become dormant (inactive), there is most often no
justification to keep a copy of that record for the remainder of the
original's retention period. This practice will essentially double the cost
of managing that record through the inactive part of its life-cycle.
Generally, a record is only kept in duplicate at a separate location when
that record is considered vital to the ongoing operation of the company.
This usually applies to only about 2% of the total records volume as
determined by the individual organization.
We believe that 257.1 (e) (2) (iii) should not be included in the proposed
amendments.
Mr. Lorrin Read, CRM
Director, Corporate Records Management
FirstEnergy Corporation
Akron, OH 44308-1890
readl@firstenergycorp.com